SMT. SATYAWATI MARWAHA THROUGH LEGAL HEIR SH, CHANDER SHEIKHAR MARWAHA,JALANDHAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, JALANDHAR

In the result, the appeal for Asstt

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

38, where it was held as under: 12 I.T.A. Nos. 346 & 347/Asr/2024 Assessment Years: 2014-15 & 2015-16 "Sec. 147 empowers the AO to assess or reassess income chargeable to tax if he has reasons to believe that the income for any assessment year has escaped assessment. The power conferred under this section is very wide, but at the same

SHRI KASHMIR SINGH S/O SHRI SHINGARA SINGH,AMRITSAR vs. INCOME TAX OFFICER, WARD-5(3), AMRITSAR

Bench: Sh. Ravish Sood & Dr. M. L. Meena

10 Notices u/s 148, dated 29.03.2016, both of which were backed by separate ‘reasons to believe’. As both the Notices u/s 148 haver been issued on the same date, i.e, on 29.03.2016, therefore, it would be important to determine as to which of them was issued prior to the other. As the necessary sanction/approval from the Pr. Commissioner of Income

SHRI JASBIR SINGH ,JALANDHAR vs. INCOME TAX OFFICER,WARD-I (2), JALANDHAR

In the result, the appeal of the assessee is allowed

Bench: Shri N.K. Choudhry, Jm & Dr. A.L.Saini, Am आयकरअपीलसं./Ita No.426/Asr/2018 ("नधा"रणवष" / Assessment Year: 2011-12)

reassessed to confer jurisdiction under section 147(a) two conditions were required to be satisfied: firstly the Assessing Officer must have reason to believe that income, profits or gains chargeable to, income tax have escaped assessment, and secondly he must also have reason to believe that such escapement has occurred by reason of either omission or failure on the part

SAINIK CO OPERATIVE HOUSE BUILDING SOCIETY LIMITED,JAMMU AND KASHMIR vs. ITO WARD 1(1), JAMMU, JAMMU

In the result the appeal of the assessee is allowed on the legal issue as indicated above

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta(Hybrid Hearing) I.T.A. No. 698/Asr/2024 Assessment Year: 2013-14

147 - period of limitation - notices issued u/s 148 of the old regime - HELD THAT:- A notice under Section 148 of the IT Act accompanied by an order under Section 148A (d) is required to be issued within the time stipulated under Section 149 of the IT Act. Section 148A (d) does not govern the computation of time as contemplated

MESERS SUPERTECH FORGINGS(INDIA) PVT.LTD.,JALANDHAR vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE IV, JALANDHAR

In the result, the appeal of the Assessee is allowed

38(P&H), held as follows (head note): “—Reason to believe—Information from Survey Wing of the Department—AO can assume jurisdiction under s. 147 provided there is sufficient material before him and the existence of material must be real—Further, there must be nexus between the material and the escapement of income—AO has to record reasons showing

NASA AGRO INDUSTRIES PRIVATE LIMITED,FAZILKA vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-II, BATHINDA

In the result, the appeal filed by the assessee is allowed for statistical purpose

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

10. 200 TTJ (Jd) 273 Vined Commodities Ltd. ACIT AO having recorded reasons for reopening the assessee's assessment simply by taking note of the information received from the Addl. Director of IT (Inv.), without any verification or enquiry to form the conclusion that assessee's income chargeable to tax has escaped assessment, without independent application of mind, the assumption

SH. KARAMJIT SINGH RAI,HOSHIARPUR vs. INCOME TAX OFFICER , HOSHIARPUR

In the result, appeal filed by the Assessee is allowed

Bench: Sh. N.K.Choudhry & Dr. A.L.Saini

u/s 147 in the instant case have been initiated on the basis of suspicion and there was absolutely no material on record, by which it can be said that there was any reason(s) to believe before the AO qua escapement of income. The Jurisdictional High Court in the case of Commissioner of Income Tax vs. Smt. Pramjit Kaur

SH. PUNEET SEHDEV PROP,JAMMU vs. THE INCOME-TAX OFFICER, JAMMU

Bench: Shri L. P. Sahu & Shri Ravish Sood

147, dated 26.03.2013 had in the mean time again disallowed the assessee’s claim for deduction u/s 80IB of the Act. On further appeal, the CIT(A) observed that he had while disposing off the appeal of the assessee for A.Y 2009-10 had upheld the disallowance of the assessee’s claim for deduction that involving identical facts was raised

PUNEET SAHDEV,JAMMU vs. THE INCOME TAX OFFICER, JAMMU

Bench: Shri L. P. Sahu & Shri Ravish Sood

147, dated 26.03.2013 had in the mean time again disallowed the assessee’s claim for deduction u/s 80IB of the Act. On further appeal, the CIT(A) observed that he had while disposing off the appeal of the assessee for A.Y 2009-10 had upheld the disallowance of the assessee’s claim for deduction that involving identical facts was raised

SH. PUNEET SEHDEV PROP;,JAMMU vs. THE INCOME-TAX OFFICER,, JAMMU

Bench: Shri L. P. Sahu & Shri Ravish Sood

147, dated 26.03.2013 had in the mean time again disallowed the assessee’s claim for deduction u/s 80IB of the Act. On further appeal, the CIT(A) observed that he had while disposing off the appeal of the assessee for A.Y 2009-10 had upheld the disallowance of the assessee’s claim for deduction that involving identical facts was raised

INCOME TAX OFFICER, JAMMU vs. SH. PUNEET SEHDEV, PROP., JAMMU

Bench: Shri L. P. Sahu & Shri Ravish Sood

147, dated 26.03.2013 had in the mean time again disallowed the assessee’s claim for deduction u/s 80IB of the Act. On further appeal, the CIT(A) observed that he had while disposing off the appeal of the assessee for A.Y 2009-10 had upheld the disallowance of the assessee’s claim for deduction that involving identical facts was raised

INCOME TAX OFFICER WARD -2 (1), AMRITSAR vs. MS. SAVITA BANSAL, THROUGH LEGAL HEIR SH. PARVEEN KUMAR BANSAL, AMRITSAR

In the result, the revenue’s appeal stands dismissed

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Udayan Das Gupta, Jm 1. आयकर अपील सं. / Ita No. 240/Asr/2023 (िनधा"रण वष" / Assessment Year: 2016-17) Income Tax Officer Smt. Savita Bansal Ward-2(1) बनाम/ (Through L/H Shri Parveen Kumar Bansal) Amritsar 143001 H.No. 272, Green Avenue Vs. Amritsar-143001. "थायीलेखासं./Pan. Abmpb-3594-K (Assessee) / Acnpk-4131-D (Lh) (अपीलाथ"/Appellant) : (""थ" / Respondent) & 2. Cross Objection No. 1/Amritsar/2024 (In Ita No. 240/Asr/2023) (िनधा"रण वष" / Assessment Year: 2016-17) Smt. Savita Bansal Income Tax Officer बनाम/ (Through L/H Shri Parveen Kumar Bansal) Ward-2(1) H.No. 272, Green Avenue Amritsar 143001 Vs. Amritsar-143001. "थायीलेखासं./Pan. Abmpb-3594-K (Assessee) / Acnpk-4131-D (Lh) (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/Appellant By : Dr Rakesh Gupta (Advocate) –Ld. Ar ""थ"कीओरसे/Respondent By : Shri B. Srinivas Kumar (Cit) – Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 10-07-2025 घोषणाकीतारीख /Date Of Pronouncement : 21-08-2025 आदेश / O R D E R Manoj Kumar Aggarwal () Aforesaid Appeal By Revenue For Assessment Year (Ay) 2016- 1. 17 Arises Out Of An Order Of Ld. Commissioner Of Income Tax

10(38) was considered to be bogus and accordingly, added to the returned income of the deceased assessee. 3.2 The Ld. CIT(A), after considering assessee’s submissions as well as remand report and assessee’s rejoinder thereto, observed that no documentary evidence was brought in by Ld. AO to support the allegations. The prices of the impugned scrips were

LATE. SH. GURMAIL. SINGH. S/O. SH. LAL SINGH,SRI MUKATSAR vs. DY.COMMISSIONER OF INCOME TAX CIRCLE -II, BATHINDA

Appeals are disposed of in the terms and observation made as above

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

reassessment proceedings were mounted. The levy of penalty was justified hence the grounds of appeal are dismissed.” 30. The Ld. AR contended that the cryptic and non-speaking order passed under section 250(6) by the ld. Commissioner of Income Tax (Appeals), Bathinda in Appeal No. 135-IT/17-18 dated 12.11.2018 is contrary to law and facts of the case

SH. ARASHPREET SINGH. S/O.LATE.SH. GURMAIL SINGH,MUKTSAR vs. DY. COMMISSIONER OF INCOME TAX .CIRCLE-II, BATHINDA

Appeals are disposed of in the terms and observation made as above

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

reassessment proceedings were mounted. The levy of penalty was justified hence the grounds of appeal are dismissed.” 30. The Ld. AR contended that the cryptic and non-speaking order passed under section 250(6) by the ld. Commissioner of Income Tax (Appeals), Bathinda in Appeal No. 135-IT/17-18 dated 12.11.2018 is contrary to law and facts of the case

SH. ARASHPREET SINGH S/O LATE SH. GURMAIL SINGH,SHRI MUKATSAR vs. DY. COMMISSIONER OF INCOME TAX CIRCLE-II, BATHINDA

Appeals are disposed of in the terms and observation made as above

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

reassessment proceedings were mounted. The levy of penalty was justified hence the grounds of appeal are dismissed.” 30. The Ld. AR contended that the cryptic and non-speaking order passed under section 250(6) by the ld. Commissioner of Income Tax (Appeals), Bathinda in Appeal No. 135-IT/17-18 dated 12.11.2018 is contrary to law and facts of the case

SH. ARASHPREET SINGH S/O. LATE SH. GURMAIL SINGH,MUKTSAR vs. DY. COMMISSIONER OF INCOME TAX CERCLE- II, BATHINDA

Appeals are disposed of in the terms and observation made as above

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

reassessment proceedings were mounted. The levy of penalty was justified hence the grounds of appeal are dismissed.” 30. The Ld. AR contended that the cryptic and non-speaking order passed under section 250(6) by the ld. Commissioner of Income Tax (Appeals), Bathinda in Appeal No. 135-IT/17-18 dated 12.11.2018 is contrary to law and facts of the case

SH. ARASHPREET SINGH S/O. LATE SH. GURMAIL SINGH,MUKTSAR vs. DY. COMMISSIONER OF INCOME TAX CIRCLE-II, BATHINDA

Appeals are disposed of in the terms and observation made as above

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

reassessment proceedings were mounted. The levy of penalty was justified hence the grounds of appeal are dismissed.” 30. The Ld. AR contended that the cryptic and non-speaking order passed under section 250(6) by the ld. Commissioner of Income Tax (Appeals), Bathinda in Appeal No. 135-IT/17-18 dated 12.11.2018 is contrary to law and facts of the case

LATE. SH. GURMAIL SINGH S/O. SH. LAL SINGH,SRI MUKATSAR vs. DY.COMMISSIONER OF INCOME TAX CIRCLE -II, BATHINDA

Appeals are disposed of in the terms and observation made as above

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

reassessment proceedings were mounted. The levy of penalty was justified hence the grounds of appeal are dismissed.” 30. The Ld. AR contended that the cryptic and non-speaking order passed under section 250(6) by the ld. Commissioner of Income Tax (Appeals), Bathinda in Appeal No. 135-IT/17-18 dated 12.11.2018 is contrary to law and facts of the case

SH. ARSPREET SINGH . S/O. LATE. SH. GURMAIL SINGH ,MUKTSAR vs. DY. COMMISSIONER OF INCOME TAX CIRCLE .II, BATHINDA

Appeals are disposed of in the terms and observation made as above

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

reassessment proceedings were mounted. The levy of penalty was justified hence the grounds of appeal are dismissed.” 30. The Ld. AR contended that the cryptic and non-speaking order passed under section 250(6) by the ld. Commissioner of Income Tax (Appeals), Bathinda in Appeal No. 135-IT/17-18 dated 12.11.2018 is contrary to law and facts of the case